New Mexico Supreme Court
State v. Mendez
July 13, 2026
Summary
The Court held that Defendant preserved his challenge to Juror 6, whose voir dire statements collectively demonstrated actual bias favoring law enforcement and undermined the presumption of innocence. Because the district court improperly denied the challenge, Defendant used a peremptory challenge to remove Juror 6 and exhausted his remaining peremptory challenges before jury selection ended, establishing prejudice under state law. The Court declined to overrule the governing prejudice rule and reversed the conviction for a new trial.